G.R. No. 162037 - Heirs of Diaz vs. Virata

The case is an administrative complaint for Gross Ignorance of the Law filed by Miguel Argel (Complainant) against Judge Herminia M. Pascua of RTC-Br. 25, Vigan, Ilocos Sur (Respondent).
The complaint arose from the issuance of two conflicting decisions by Respondent in connection with Crim. Case No. 2999-V.

On 22 July 1993, Respondent rendered a Decision of acquittal in People v. Miguel Argel, which was promulgated on 13 August 1993.
Later, on 19 August 1993, Respondent “revised” her previous Decision and rendered a decision convicting Miguel Argel of murder.
The conflict arose because the initial acquittal had already attained finality, invoking the constitutional prohibition on double jeopardy.

In a letter-explanation dated 7 March 1994, Respondent alleged that her initial decision of acquittal was based on the absence of an attached transcript of the eyewitness testimony.
Upon being notified by a lawyer representing a private complainant about the existence of the eyewitness testimony of Tito Retreta, Respondent re-read her notes and confirmed the testimony before “revising” her decision.
Respondent explained that she intended to use the second decision not to incarcerate the accused immediately but to notify him and require him to answer for civil liabilities arising from the crime.

Before Respondent could personally explain her revised decision to Complainant, the latter’s brother filed a petition for habeas corpus before the Court of Appeals.
Respondent expressed her intent to await the hearing of the petition prior to setting Complainant free, so that she could provide him a copy of the revised decision.
Complainant also charged Respondent with gross negligence related to her failure to ensure that all proper transcripts of stenographic notes were attached to the record before she rendered her decision.

A memorandum dated 11 May 2001 from the Office of the Court Administrator recommended a fine of P20,000.00 for Respondent for gross ignorance of the law.
It was noted that Respondent had been compulsorily retired as of 18 September 1998, and thus the fine was to be deducted from her retirement benefits.

The initial judgment of acquittal rendered on 13 August 1993 was declared final and immune from amendment because a judgment of acquittal in criminal cases becomes final immediately upon its promulgation.
The act of “revising” a final and immutable decision violated the elementary rule that once final, a decision cannot be altered except under limited circumstances (clerical errors, ambiguities in the dispositive portion, or correcting a travesty of justice).

Whether a judgment of acquittal in a criminal case, once final and promulgated, is immutable and beyond revision.

Whether the "revision" of the acquittal by Respondent, despite being fully aware of its finality, violated the constitutional protection against double jeopardy.
Whether the act of "revising" the decision falls under gross ignorance of the law given the unequivocal legal rule regarding the finality of judgments of acquittal.

Whether Respondent’s failure to exercise extreme caution in preparing her decision—including the oversight of not ensuring the attachment of the transcript of the eyewitness testimony—constituted judicial negligence.
Whether such negligence, evidenced by the subsequent “revision” of a final decision, justifies the imposition of an administrative fine.

Whether the inherent power of the court to correct errors extends to modifying a final judicial decision.
Whether the purpose of notifying the complainant of civil liabilities in lieu of incarceration can legally justify revising a final judgment.